Finding 1206883 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-04-15
Audit: 398883
Organization: Silent Cooperative Apartments (IL)
Auditor: WIPFLI LLP

AI Summary

  • Issue: Five tenant files were missing required signed leases, violating HUD regulations.
  • Impact: This lack of documentation increases the risk of financial penalties and challenges in enforcing lease terms.
  • Recommendation: Improve internal controls to ensure all tenant files contain the necessary signed lease agreements.

Finding Text

Condition: The required signed leases were not properly included in five of the tenant files. Criteria: According to HUD regulations, Public Housing Agencies (PHAs) are required to have a signed, written lease agreement in the tenant's file for all assisted units. The signed lease agreement must be included in the tenant file to ensure compliance with federal requirements. Cause: The absence of lease agreements in the tenant file was due to a lack of proper documentation and inadequate internal controls to ensure compliance with HUD requirements relating to complete and accurate tenant files. Effect: Without the proper lease documentation, there is an increased risk of disallowed costs, repayment of funds from HUD, and inability to enforce program requirements such as rent increases or lease violations, which could result in questioned costs and potential repayment of federal funds.

Corrective Action Plan

Recommendation: We recommend that management and those charge with governance to improve internal controls to ensure that all required lease agreements are included in tenant files. Response: As of March 2026, to prevent recurrence, management has implemented the following procedural changes: 1. The move in checklist will add a line requiring staff sign-off confirming that all executed lease documents are placed in the tenant file prior to move-in or lease renewal. 2. Property management staff will conduct monthly file reviews to verify that all move in’s required documentation, including signed lease agreements, is present and current in each tenant file. 3. The Regional Manager will conduct quarterly file audits to ensure ongoing compliance and will report findings to management.

Categories

HUD Housing Programs

Programs in Audit

ALN Program Name Expenditures
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $4.54M
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $1.66M